Alliance for Chemical Distribution
AdvocacySupport
Notice 2026-23
IRS-2026-0364-0001Notice
Comments
149
Last activity Jul 7, 2026
Deadline
Closed on May 30, 2026
Closed May 30, 2026
Net supportiSupport minus oppose · campaigns included
+95%
+95% excluding campaigns
Document
Details
The document's own metadata, straight from the source system.
- Title
- Notice 2026-23
- Posted
- Mar 23, 2026
- Comment period
- Mar 23, 2026 – May 30, 2026
Analysis
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Include campaigns
Stance breakdown
+95%
Net support
Support143Oppose1Other5
Aggregates include form-letter campaigns. Excluding them, net support is +95% across organic comments.
Who commented
Breakdown by commenter type.
Government
7
Individual
19
Trade association
20
Advocacy
63
Academic
2
Business
35
Other
3
Comments over time
Weekly arrivals, stacked by stance.
Posted Mar 23, 2026Deadline May 30, 2026
Mar 23Apr 13Apr 27May 11May 25Jun 8Jun 22Jul 6
Support143Oppose1Other5
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Advocacy
100%
0%
0%
Business
100%
0%
0%
Trade association
100%
0%
0%
Individual
79%
5%
16%
Government
100%
0%
0%
Other
33%
0%
67%
Academic
100%
0%
0%
Issues raised
The docket's canonical issues. Select one to browse its comments.
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Uncheck an issue to choose another.
| Organization | Carbon capture tax credit | Fuel excise tax pto | Nuclear energy tax guidance | Semiconductor materials tax credit | Inbound transaction regulations |
|---|---|---|---|---|---|
Alliance for Chemical Distribution AdvocacySupport The Alliance for Chemical Distribution (ACD) requests that the IRS include final regulations regarding Superfund chemica | · | · | · | · | · |
American Benefits Council AdvocacySupport The American Benefits Council, an employee benefits public policy organization, urges the Treasury and IRS to issue offi | · | · | · | · | · |
American Carbon Alliance AdvocacySupport The American Carbon Alliance, a coalition of agricultural, biofuels, and energy stakeholders, requests that the Treasury | · | · | · | · | |
Aon BusinessSupport Aon plc, a global professional services firm, submitted recommendations for the 2026-2027 Priority Guidance Plan. | · | · | · | · | · |
Baker Botts L.L.P. BusinessSupport Baker Botts LLP, representing a client, requests that the IRS include guidance on section 45Q(d)(2)(B) for carbon captur | · | · | · | · | |
Carbon Utilization Research Council AdvocacySupport The Carbon Utilization Research Council (CURC), an industry coalition, supports the inclusion of updated regulatory guid | · | · | · | · | |
CEMEX INC BusinessSupport Cemex, Inc., a leading U.S. | · | · | · | · | |
CF Industries BusinessSupport CF Industries, a leading ammonia producer, recommends that updating the regulations under Section 45Q be included in the | · | · | · | · | |
CO2 Solutions Coalition AdvocacySupport The CO2 Solutions Coalition, representing carbon dioxide suppliers and end-users, urges the Treasury Department to inclu | · | · | · | · | |
Combined Heat and Power Alliance AdvocacySupport The Combined Heat and Power Alliance urges the Treasury and IRS to prioritize amending regulations for Sections 45Y and | · | · | · | · | · |
Committee of Annuity Insurers AdvocacySupport The Committee of Annuity Insurers, a coalition of life insurance companies, submitted recommendations for the 2026-2027 | · | · | · | · | · |
Edison Electric Institute Trade associationSupport The Edison Electric Institute and the Nuclear Energy Institute are requesting that the Treasury and IRS include nuclear- | · | · | · | · | |
Edison Electric Institute, Nuclear Energy Institute, Geothermal Rising Trade associationSupport The Edison Electric Institute, Nuclear Energy Institute, and Geothermal Rising Action are requesting that the Department | · | · | · | · | |
Entegris, Inc. BusinessSupport Entegris, Inc., a semiconductor materials supplier, argues that the IRS and Treasury should include semiconductor materi | · | · | · | · | |
Environmental Solutions Group AdvocacySupport Environmental Solutions Group recommends that the Treasury and the IRS include a project on the 2026–2027 Priority Guida | · | · | · | · | |
Forefront AdvocacySupport Forefront, an Illinois-based association representing foundations and nonprofits, supports the development of the 2026-2 | · | · | · | · | · |
Fuel Cell and Hydrogen Energy Association AdvocacySupport The Fuel Cell and Hydrogen Energy Association (FCHEA) supports the proposed 2026-2027 Priority Guidance Plan and request | · | · | · | · | |
Global CCS Institute AdvocacySupport The Global CCS Institute, an international think-tank, recommends that the Department of the Treasury and the IRS includ | · | · | · | · | |
Greater Houston Partnership BusinessSupport The Greater Houston Partnership requests that the Department of the Treasury and the IRS include updating Section 45Q re | · | · | · | · | |
Historic Tax Credit Coalition AdvocacySupport The Historic Tax Credit Coalition is requesting that the IRS include three specific items on the 2026-2027 Priority Guid | · | · | · | · | · |
Holland & Knight AdvocacySupport Holland & Knight LLP, representing various interests, urges the Treasury and IRS to expand the definition of "semiconduc | · | · | · | · | |
Investment Company Institute Trade associationSupport The Investment Company Institute (ICI), a trade association representing the asset management industry, submitted recomm | · | · | · | · | · |
Miller & Chevalier Chartered BusinessSupport Miller & Chevalier Chartered, a law firm, is requesting that the IRS provide clarifying guidance on the deductibility of | · | · | · | · | · |
National Foriegn Trade Council AdvocacySupport The National Foreign Trade Council (NFTC), an association of U.S. | · | · | · | · | · |
National Payroll Reporting Consortium Trade associationSupport The National Payroll Reporting Consortium (NPRC), a non-profit trade association representing payroll service providers, | · | · | · | · | · |
National Ready Mixed Concrete Association Trade associationSupport The National Ready Mixed Concrete Association (NRMCA) is requesting that the IRS prioritize the creation of clear, simpl | · | · | · | · | |
National Waste & Recycling Association Trade associationSupport The National Waste & Recycling Association (NWRA) is requesting that the Treasury and IRS include a project on the 2026- | · | · | · | · | |
Occidental Petroleum Corporation BusinessSupport Occidental Petroleum Corporation is requesting specific clarifications and updates to the 2026-2027 Priority Guidance Pl | · | · | · | · | |
Oregon Refuse and Recycling Association Trade associationSupport The Oregon Refuse and Recycling Association (ORRA) is urging the Treasury Department and the IRS to include updated guid | · | · | · | · | |
PwC LLP BusinessSupport PricewaterhouseCoopers LLP (PwC) argues that the current "presumed gain inclusion" regulation for Opportunity Zone inves | · | · | · | · | · |
SEMI Trade associationSupport SEMI, a trade association representing the semiconductor industry, urges the Treasury and IRS to expand the eligibility | · | · | · | · | |
Skadden, Arps, Slate, Meagher & Flom LLP BusinessSupport Skadden, Arps, Slate, Meagher & Flom LLP, a law firm, requests that the Treasury and IRS open a new guidance project to | · | · | · | · | |
Sullivan & Cromwell LLP BusinessSupport Sullivan & Cromwell LLP, representing its clients, argues that the Inbound Transaction Regulations are outdated and crea | · | · | · | · | |
The Coalition for Energy Efficient Jobs & Investment AdvocacySupport The Coalition for Energy Efficient Jobs & Investment urges the Treasury and IRS to prioritize the issuance of guidance f | · | · | · | · | · |
The Kresge Foundation AdvocacySupport The Kresge Foundation is requesting that the IRS include modifications to expenditure responsibility (ER) reporting requ | · | · | · | · | · |
Waste Connections BusinessSupport Waste Connections, a solid waste services company, is urging the Treasury and IRS to include a project on the 2026-2027 | · | · | · | · |
American Benefits Council
AdvocacySupport
American Carbon Alliance
AdvocacySupport
Carbon capture tax credit
Aon
BusinessSupport
Baker Botts L.L.P.
BusinessSupport
Carbon capture tax credit
Carbon Utilization Research Council
AdvocacySupport
Carbon capture tax credit
CEMEX INC
BusinessSupport
Fuel excise tax pto
CF Industries
BusinessSupport
Carbon capture tax credit
CO2 Solutions Coalition
AdvocacySupport
Carbon capture tax credit
Combined Heat and Power Alliance
AdvocacySupport
Committee of Annuity Insurers
AdvocacySupport
Edison Electric Institute
Trade associationSupport
Nuclear energy tax guidance
Edison Electric Institute, Nuclear Energy Institute, Geothermal Rising
Trade associationSupport
Nuclear energy tax guidance
Entegris, Inc.
BusinessSupport
Semiconductor materials tax credit
Environmental Solutions Group
AdvocacySupport
Fuel excise tax pto
Forefront
AdvocacySupport
Fuel Cell and Hydrogen Energy Association
AdvocacySupport
Nuclear energy tax guidance
Global CCS Institute
AdvocacySupport
Carbon capture tax credit
Greater Houston Partnership
BusinessSupport
Carbon capture tax credit
Historic Tax Credit Coalition
AdvocacySupport
Holland & Knight
AdvocacySupport
Semiconductor materials tax credit
Investment Company Institute
Trade associationSupport
Miller & Chevalier Chartered
BusinessSupport
National Foriegn Trade Council
AdvocacySupport
National Payroll Reporting Consortium
Trade associationSupport
National Ready Mixed Concrete Association
Trade associationSupport
Fuel excise tax pto
National Waste & Recycling Association
Trade associationSupport
Fuel excise tax pto
Occidental Petroleum Corporation
BusinessSupport
Carbon capture tax credit
Oregon Refuse and Recycling Association
Trade associationSupport
Fuel excise tax pto
PwC LLP
BusinessSupport
SEMI
Trade associationSupport
Semiconductor materials tax credit
Skadden, Arps, Slate, Meagher & Flom LLP
BusinessSupport
Inbound transaction regulations
Sullivan & Cromwell LLP
BusinessSupport
Inbound transaction regulations
The Coalition for Energy Efficient Jobs & Investment
AdvocacySupport
The Kresge Foundation
AdvocacySupport
Waste Connections
BusinessSupport
Fuel excise tax pto
3 organization-typed comments could not be identified.
Comments
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
Filter:
- May 29, 2026NareitSupportAdvocacy📎 Attachment
Nareit, the National Association of Real Estate Investment Trusts, is submitting a series of recommendations for the 2026-27 IRS Priority Guidance Plan. They argue for specific regulatory clarifications regarding data center construction assets, constructive ownership rules, REIT liquidations, and on-site energy deployment to reduce uncertainty and administrative burdens for the REIT industry.
Read comment → - May 29, 2026SIFMA and SIFMA Asset Management GroupSupportTrade association📎 Attachment
The Securities Industry and Financial Markets Association (SIFMA) and its Asset Management Group support a recommendation to clarify that overnight U.S. Treasury reverse repurchase transactions cleared through the FICC are not treated as securities subject to the 5% asset test. They argue that treating these transactions as securities issued by a single issuer would unduly restrict mortgage REITs' ability to manage interest rate risk and invest in these highly liquid and safe assets.
Read comment → - May 4, 2026Anonymous AnonymousSupportIndividual
The commenter requests that the Treasury Department and the IRS include specific guidance in the 2026–2027 Priority Guidance Plan regarding the application of IRC §1231(c) to real estate investment trusts (REITs). They argue that the current interaction between these tax rules unfairly penalizes REIT investors by recharacterizing capital gain dividends as ordinary income due to entity-level losses.
Read comment →